Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The case pertains to tax deducted at source (TDS) by the respondent from the petitioner's income but not deposited with the tax authorities. The petitioner claimed non-liability to pay tax deducted by the respondent, as reflected in Form 16A. The revenue pointed out adjustments for different assessment years. The court held that the adjustment for the assessment year 2017-18 was permissible, as the outstanding demand of Rs. 42,070 was recoverable. However, for the assessment years 2009-10, 2010-11, and 2011-12, the adjustment was set aside in favor of the petitioner, following a previous decision. The impugned notices and order were set aside for those assessment years, and the revenue was directed to pass necessary consequential orders accordingly.
The case pertains to tax deducted at source (TDS) by the respondent from the petitioner's income but not deposited with the tax authorities. The petitioner claimed non-liability to pay tax deducted by the respondent, as reflected in Form 16A. The revenue pointed out adjustments for different assessment years. The court held that the adjustment for the assessment year 2017-18 was permissible, as the outstanding demand of Rs. 42,070 was recoverable. However, for the assessment years 2009-10, 2010-11, and 2011-12, the adjustment was set aside in favor of the petitioner, following a previous decision. The impugned notices and order were set aside for those assessment years, and the revenue was directed to pass necessary consequential orders accordingly.
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